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CITY of BAKERSFIELD
"WE CARE"
FIRE DEPARTMENT
D. S. NEEDHAM 2101 H STREET
FIRE CHIEF BAKERSFIELD. 93301
326-39~
December 13, i990
Mr. W.J. Callahan
Sr. Technical Consultant
Linde Gases
2678 Bishop Drive, Suite ZOO
San Ramon, CA 94583
Dear Mr. Callahan,
I have reviewed the Risk Management and Prevention Program IRMPP)
which you submitted regarding the storage of anhydrous ammonia and
gaseous chlorine at 3808 Pierce Road in Bakersfield. 'This RMPP satisfies
the requirements of Chapter 6.98, Sections 28531 et aec, of the
California Health and Safety Code and has been accepted by the
Bakersfield Fire Department. Bakersfield Fire will inspect your facility
periodically to verify compliance with the' program proposed in your
RMPP.
Please use the attached forms to update your Hazardous Materials
Business Plan to reflect the deletion of anhydrous ammonia and chlorine
resulting from implementation of the RMPP. Return the inventory updates
to Bakersfield Fire Hazardous'Materials Division at the time the changes
take place.
Thank you for all of your cooperation during the development
.this Risk Management and Prevention Program. Please call me if I can be
of any further assistance in hazardous materials planning.
Sincerely,
Barbara Brenner
Hazardous Materials Piannin~'Technician
2678 Bishop Drive, Suite 200
San Ramon, CA 94583
Caller Service 5161
(415) 277-2100
(415) 866-8618
December 6, 1990
RECEIVED
DEC 1 1 1990
Ans'd ............
City of Bakersfield
Fire Department
2101 H Street
Bakersfield, CA. 93301
Attn: Barbara Brenner
Hazardous Materials Planning Technician
Dear Barbara:
In order to meet the requirements of the RMPP, we have reduced to zero
the quantities of Ammonia and Chlorine stored at our facility located at
3505 Pierce Road, Bakersfield, California. This will be completed as of
December 15, 1990.
If there is any need for you contact me further, I can be reached, at
(415) 277-2163.
Very truly yours,
W. J. Callahan
Sr. Technical Consultant
WJC/sll
Encl.
cc: M. Cooper
D.F.E. Davis
· ' CITY of BA KERSFfEL D
"WE C,4RE" ~ ~
FIRE DEPARTMENT 210i H STREET
D. S. NEEDHAM BAKERSFIELD. 93301
FIRE CHIEF . 326-3911
November 20, 1990'
Mr. W.J. Callahan
Linde Gases of the West, Inc.
2678 Bishop Drive, Suite 200
San Ramon, CA 94583
Dear Mr. Callahan:
Thank you for the timely submittal of your plan to eliminate the
storage of a~u~onia and chlorine from the Bakersfield, Pierce Road
Facility. I must, however, require some amen~Lments to this letter
before I can accept it as a RMPP. The proposed plan, to eliminate
chlorine and ammonia storage, is the Risk Management and Prevention
Plan. The requirement for the completion of a RMPP will not be
rescinded due to the elimination of these acutely hazardous materials at
the Pierce Rd. facility, but it will be satisfactorily fulfilled by this
plan. Your letter will serve as the RMPP and must address the plan for
elimination of these products from this point of view.
I also request that you clearly state that the quantities of
ammonia and chlorine stored at 3505 Pierce Rd. will be reduce to zero
pounds. Please state a date by which the plan will be implemented.
Call me at (805) 326-3979 if I can help clarify the requirements that I
outlined above or if you would like to check the wording of your RMPP
· before sending it. Please submit the revised RMPP by December 8, 1990.
Thank you for all of your cooperation.
Sincerely,
Barbara Brenner
Hazardous Materials Planning Technician
the ~ · 2678 Bishop Drive, Suite 200
..... San Ramon, CA 94583
Caller Service 5161
(415) 277-2100
(415) 866-8618
November 13, 1990
Barbara Brenner
Hazardous Material Planning Technician
2101 H. Street
Bakersfield, CA. 93301
Dear Barbara:
We have decided to eliminate both Ammonia and Chlorine from our
property at 3505 Pierce Road, this eliminating the need for a RMPP.
If you have any questions, please contact me at (415) 277-2163.
Very truly yours,
W. d. Callahan
Sr. lechnical Consultant
WdC/sl 1
cc: D.F.£. Davis
d.F. Cash
M. Cooper
CITY
210~ H STREET
FIRE CHIEF ~ ~ 326-3911
September
Mr. S.J. Rohn
Linde Bases West, Inc.
26?8 Bishop Drive
San Ramon, Ch 94583
Oear Mr. Rohn,
Having revieued your statement of qualifications for the
RMPP preparation team, I am left with several concerns regarding
the team's experience in the field of chemical risk analysis.
Due to the reactivity of ammonia and chlorine wi{h each other and
other gases 'which are stored at the facility, this 6dministering
hgency requires that one Member of the team have a degree in
Chemistry or Chemical Engineering, We also .require RMPP
preparers to have prior experience in the fields of rise analysis
and hazard evaluation. Specific information documenting this
training and experience must be submitted before we can accept
the proposed team as qualified for this project.
Please submit the information requested above, in addition
to the answers to questions )-~ on the second page of the
qu&lifications questionnaire, by September 28, 1990. I will also
need documentation regarding the WHhZhN air dispersion model.
Please ~nctude information defining the Model's capabilities and
typical input parameters. This model must be able to adequately
handle gases which are denser than air.
Please call, 805-326-3979, i? I can be of any assistance.
Sincerely,
Barbara Brenner
Hazardou~ Materials Planning Technician
of
GASES WEST, INC
of Linde Gases West, Inc.
2~78 Bishop Drive, Su/te 200
the ' San Ramon, CA 94583
Caller Service 5161
(415) 277-2100
(415) 866-8618
August 30, 1990
Bakersfield Fire Department
Hazardous Materials Division
2130 "G" Street
Bakersfield, CA. 93301
Attn: Barbara Brenner
SUBJECT: RMPP - BAKERSFIELD
Dear Barbara:
Union Carbide Linde Division has over 80 years experience in the
industrial and specialty gas business. The risk analysis team will be made
up of several employees from Linde.
The team members will include:
Sam Rohn Haz Op Team Leader - BS in Safety/Health.
Bill Callahan Senior Technical Consultant Operations - 25 years with
Linde.
Frank Klipp Manager - Operations Technical Engineer - 20 + years with
Linde.
The persons listed above will be the primary players in putting
together the risk and consequence analysis. Other Linde technical
personnel will be asked to assist as required.
We have data already established from work done at several other sites
across the U.S. involving the acutely hazardous substances at our
Bakersfield facility. We will be utilizing the "WHAZAN" air dispersion
model for our risk analysis. We will be looking at the IDLH levels for a
worst-case episodic incident (ie. failure of the container or valve).
As I gather additional data, I will forward it on to you. We are
still considering the prospect of eliminating both ammonia and chlorine
from our property.
If you need more information at this time, please contact the writer.
Yours truly,
S. d. Rohn
LGW SHEA Coordinator
SJR/sll
May 25. '1990
Baker's IJelding Supply. Bayox [nc.
3505 Pierce Road
Bakersfield. CA 93309
Bear Mr. Starr ~
In DeceMber of 1989.~ this Administering Agency requested
tha~ your business co~pla~e a Risk Management and Prevention
Progra~ in regard ~o your handling of anhydrous a~onia and
chlorine g~s. The due date for co~pla~ion of ~he RMPP
December ~ 1~90. Our experience ~i~h ~his proces~
thai. ii takes r~ost businesses several ~on~hs to locate
8ccept~ble bid fro~ ~ fir~ or individuB1 qualified to conduct
this type of ri~k analysis. The actual risk analysis, review
process and RMPP preparation then requires several more
r~onihs to conplete.
~e have not heard froe} you regarding your progre~
toward RMPP completion. ~ a. requesting th~t you begin
no~. so that you ~ill be able to neet the December deadline.
Ii is ~i,e to identify the tea, ~ho ~ill be conducting the
ri~k analysis and the tea, leader ~ho ~ill be responsible for
confirm, before ~ork begins, that the team you select for
this project Meet~ the standards of this ~dMinisiering Agency
as qualified for RMPP c~ciificatioo Attached is a
questionnaire which we ore using in order to verify that the
preparor of an ~MPP is experienced in the field of risk
analysis. The second questionnaire, regarding the plan for
ci~k assessnent, will give you an understanding of the type
of study which ~e require.
Please prepare a SUMMary. addressing the attached
questions, of ~he qualifications of the risk analysis team
and RMPP preparoc. The qualification SUnMary MUSt be
submitted by 8ugt~st-l S. 1990 in order to leave adequate time
for revie~ and RMPP preparation. ~11 sub, trials should be
Made
The Bakersfield Fire Depart.eat
}{azardous Materials Division
21 30 G St.
Bakersfield. C~ 93301
If you have any questions or need help getting started
on this process, please call ,e at 393-39V9.
Sincerely.
Barbara Brenner
H~z~rdou~ .aieria~ Planning Technician
RECOMMENDED QUALIFICATIONS
FOR COMPLETION OF:
THE HAZARD-OPERABILITY STUDY
THE RMPP
CERTIFICATIOH OF THE RMPP
The R~sk Management and Prevention Program nust be
based upon the findings of R±sk and Consequence Analyses
completed by a technically qualified team. The Rlsk Analysis
..... ---, or Hazard and Operability study team ~embers should represent
a uariety of disciplines reflecting the specif±c processes
and Mater±als applications at 'the facillty . Generally, these
teams w±11 include members fron the disc~pilnes of:
Engineering
Health and Safety
Maintenance
Operations
Depending upon complex±tv of the operations, engineering
and naintenance expertise may fall ~nto the areas of chen~cal
Mechanical or electr±cal. The tean leader, the responsible
party who May ce~t±fV the document as conple~e, nag be a
genera11±st. Noueuer, the tean leader Must possess
suffic±ent ,anagement ability and expertise to understand the
uar~ous components of the R~sk Analys±s, Hazard Eualuat~on
and Risk Management and Preuent±on Program.
To determine the qual±ficat~ons of the tean it will
be necessary to address the folZow~ng questions:
1. Uho ~i11'be members of the Hazard and Operability
Study Tea~ ? Protrude the following ±nformation:
Na~e of each Member
Experience in Hazard and Operability Studies
Educational background
Process Exper±ence
2. Uho u~11 be the Haz-Op tean leader and wha'~ are the±r
qualifications or training ?
3.Oho ~11 conduct the Consequence Analysis and uhat are
their qualifications or tra±ning ?
Oho uill perform quality control for 'the Hazard and
Operability Study and ~hat are their qualifications
or training ?
A sun.ary addressing the qualifications of the Haz-Op team
and RMPP preparor must be submitted to this office for
approval bv August 1.S. 1990.
The approved team will then need to consider the
following questions and submit a plan for the Risk Analysis.
1. How do you propose to estimate the probability of
equipment failure ?
What external events . in addition to an earthquake
of 8.3 magnitude, do you plan to evaluate as a part
of the Hazard and Operability Study ?
What factors do you plan to consider when conducting
a vulnerability analysis ?( Factors contributing to size
of and consequence to the vulnerable zone.)
9..Uhich air model do 9ou plan to use for the dispersion
analysis ?
5.What Methodology will be used for estimation of
human error < operating error ) probabi!lt9 ?
Uho will assign the operating error probabilities and
what qualifications does this person have for thls
assignment ?
CITY of BAKERSFIELD
"WE CARE" ~ ~,~.~ -~
December 8, lUU9
FIRE DEPARTMENT 2107 H STREET
D. S. NEEDHAM BAKERSFIELD, 93307
FIRE CHIEF 326-3911
Bakers We±d±ng
3505 P±erce
Bakersfield, Ca 93309
Dear Don
Your bus&ness Ba~ers We±d&n~, ~oo~ed ~ 3505 P&eroe
Road, has been 2den~±f±ed &s a handZer o~ Ch±or&ne Gas
Anhydrous ABmon±a bo~h Acu~e&¥ H&sardous Ma~er±a±s. I~ has
been de~er~±ne~ ~ha~ ~our opera,±on ma~ presen~ an
requ&red ~o subm&~ a R±s~ ~ana~emen~ an~ PreYen~±on
The RMP~ sba&& &nctu~e ~he ~o&±o~&ng e~emen~s:
A DESCRIP?ZON O~ EAC~ ACCIDENT INVOLVING ACUTELY
HAZARDOUS MATERIALS WHZC~ HAS OCCURRED AT THE BUSINESS OF
~ACILZTY WITHIN TBRE~ YEARS FROM THE DAT[ OF T~E R~UEST
MADE ?URSUA~T TO SUBDIVISION (A}, TOGETHER ~ITH A
D~SCRZPTZON OF T~E UNDERLYING CAUSES OF T~E ACCIDENT AND
THE MEASURES TAEEN, IF ANY, TO AVOID A R[CURR~NCE OF A
SIMILAR ACCIDENT.
A REPORT SPECIFYING THE NATURE, AGE, AND CONDITION OF THE
EQUIPMENT USED TO HANDLE ACUTELY HAZARDOUS MATERIALS AT
THE BUSINESS OF FACILITY AND ANY SCHEDULES FOR TESTING
AND MAINTENANCE.
DESIGN, OPERATING, AND MAINTENANCE CONTROLS WHICH
MINIMIZE THE RISK OF AN ACCIDENT INVOLVING ACUTELY
HAZARDOUS MATERIALS.
DETECTION, MONITORING, OR AUTOMATIC CONTROL SYSTEMS TO
MINIMIZE POTENTIAL ACUTELY HAZARDOUS MATERIALS~ACCIDENT
RISKS.
A SCHEDULE FOR IMPLEMENTING ADDITIONAL STEPS TO BE TAKEN
BY THE BUSINESS, IN RESPONSE TO THE FINDINGS OF THE
ASSESSMENT PERFORMED PURSUANT TO SUBDIVISION (D), TO
REDUCE THE RISK OF AN ACCIDENT INVOLVING ACUTELY
HAZARDOUS MATERIALS. THESE ACTIONS MAY INCLUDE ANY OF
THE FOLLOWING.
INSTALLATION OF ALARM, DETECTION, MONITORING. OR
AUTOMATIC CONTROL DEVICES.
EQUIPMENT MODIFICATIONS, REPAIRS, OR ADDITIONS.
CHANGES IN THE OPERATIONS, PROCEDURES, MAINTENANCE
SCHEDULES, OR FACILITY DESIGN.
AUDITING AND INSPECTION PROGRAMS DESIGNED TO ALLOW THE
HANDLER TO CONFIRM THAT THE RISK MANAGEMENT AND
PREVENTION PROGRAM IS EFFECTIVELY CARRIED OUT.
RECORDKEEPING PROCEDURES FOR THE RISK MANAGEMENT AND
PREVENTION PROGRAM.
THE RMPP SHALL BE BASED UPON AN ASSESSMENT OF THE
PROCESSES, OPERATIONS, AND PROCEDURES OF THE BUSINESS,
AND SHALL CONSIDER ALL OF THE FOLLOWING:
THE RESULTS OF A HAZARD AND OPERABILITY STUDY WHICH
IDENTIFIES THE HAZARDS ASSOCIATED WITH THE HANDLING OF AN
ACUTELY HAZARDOUS MATERIAL DUE TO OPERATING ERROR,
EQUIPMENT FAILURE, AND EXTERNAL EVENTS, WHICH MAY PRESENT
AN ACUTELY HAZARDOUS MATERIALS ACCIDENT RISK.
FOR THE HAZARDS IDENTIFIED IN THE HAZARD AND OPERABILITY
STUDIES, AN OFFSITE CONSEQUENCE ANALYSIS WHICH, FOR THE
MOST LIKELY HAZARDS, ASSUMES PESSIMISTIC AIR DISPERSION
AND OTHER ADVERSE ENVIRONMENTAL CONDITIONS.
THE RISK MANAGEMENT AND PREVENTION PROGRAM SHALL IDENTIFY, BY
TITLE, ALL PERSONNEL AT THE BUSINESS WHO ARE RESPONSIBLE FOR
CARRYING OUT THE SPECIFIC ELEMENTS OF THE RMPP, AND THEIR
RESPECTIVE RESPONSIBILITIES, AND THE RMPP SHALL INCLUDE A
DETAILED TRAINING PROGRAM TO ENSURE THAT THOSE PERSONS ARE
ABLE TO IMPLEMENT THE RMPP.
THE HANDLER SHALL REVIEW THE RISK MANAGEMENT AND PREVENTION
PROGRAM, AND SHALL MAKE NECESSARY REVISIONS TO THE RMPP AT
LEAST EVERY THREE YEARS, BUT, IN ANY EVENT, WITHIN 80 DAYS
FOLLOWING A MODIFICATION WHICH WOULD MATERIALLY AFFECT THE
HANDLING OF AN ACUTELY HAZARDOUS MATERIAL.
THE RISK MANAGEMENT AND PREVENTION PROGRAM, AND ANY REVISIONS
REQUIRED BY SUBDIVISION (H), SHALL BE CERTIFIED AS COMPLETE
BY A QUALIFIED PERSON AND THE FACILITY OPERATOR.
The Health and Safety Code provides that existing
businesses handling acutely hazardous materials have t~e!ve
months from the time of notification to complete their Dian
and submit it. Your Risk Management and Prevention Program
will be due then by Decem6er 8, 1990.
We would like to review your hazard and operability
study, as well as, the offsite consequence analysis for the
hazard identified, prior to completion of your RMPP. It
would also be appropriate to review an outline of your
proposed RMPP at that meeting. Please contact this office to
schedule that meeting, allowing sufficient leadtime to
complete the RMPP,
If I can be of any assistance please don't hesitate to
call. I can be reached at 326-3979.
Sincerely Yours,
RMPPNEW.DOC